Privacy policy
In this Global Privacy Policy, “Climate Control”, “Group”, “we”, “us” and “our” means (as the context dictates) IMI Hydronic Engineering International SA, and/or the relevant members of Climate Control. The specific entity responsible for your personal information (referred to as “controller” under European data protection laws) is the entity set out in the section “Contact Us”. We are a subsidiary of IMI plc. We are committed to safeguarding the privacy of your personal information (see section 1 below).
This Privacy Policy contains important information about how we process (i.e., collect, store, use, delete etc.) personal information of our customers (including prospective customers and staff members of corporate customers), visitors to our offices/sites, individuals who visit our Climate Control websites (“Websites”) and other individuals with whom we interact both online and offline about our business (collectively “you”).
Job candidates/applicants to Climate Control should refer to our separate privacy policy on this topic which is available here - https://www.imiplc.com/candidate-privacy-notice.
1. What personal information do we process?
For purposes of this Privacy Policy, “personal information” refers to any information relating to an identified or identifiable natural person that we collect and maintain in an accessible form. This is same as the term “personal data” as used in the applicable data protection laws in the UK and the European Economic Area (EEA). Where we refer to “special categories of personal information” this means personal information that is more sensitive in nature and therefore requires a higher level of protection such as ethnic origin, health data and biometric data.
We process the following information about you which identifies you (e.g., contact details) or which can be used to identify you (e.g., that can be linked with other information). We collect this information directly from you in most cases unless stated otherwise:
Basic Account Information - Professional or investor information you provide - for example, by subscribing to newsletters, completing contact or registration forms, creating a customer account on one of our Websites and when attending events, webinars, or conferences (including videoconferences) and meetings. This includes your name, address, email address, telephone number, customer number, company details, business card information, video and audio recordings if you participate in our events and details of your employer or companies you are associated with.
Marketing Information - This includes Basic Account Information and products and services that we believe are of interest to you. We also obtain information about your product and service preferences from publicly available information.
Visitor Information - Information captured when you visit our physical sites including your name, contact details, relevant company/employer details and CCTV recordings.
Communication Information - We collect our record of correspondence between you and Climate Control, including Basic Account Information, images, recordings and correspondence submitted through the Websites.
Know-Your- Customer (KYC) Information - We process information needed to verify identity, prevent fraud, comply with legal obligations (including KYC, AML, sanctions and whistleblowing laws), protect our business and meet regulatory requirements. This may include identity and verification information, information about transactions, and information relevant to legal or regulatory checks.
Sales and Transactions information - We process Basic Account Information as well as payment information, delivery address and details of quotations, negotiations and/or transactions carried out through our Websites or through other channels and for the fulfilment of your orders. Where transactions are made on our Websites, we use third-party service providers to process your payments.
Comments - Any personal information you provide to us via comments on our Websites, on social media sites or while using online chatbot functionality.
Survey and Feedback Information - We use your name and contact information to request that you complete surveys or provide us feedback and will process any responses provided; and
Website and Communication Usage - We collect information regarding your visits to the Websites and information collected through cookies and other tracking technologies, including your IP address (a unique identifier for your computer or other device) and domain name, your browser version and operating system, traffic data, precise or general location data, web logs and other communication data and the resources that you access. For more information on our use of cookies and tracking technologies, please visit our Climate Control Cookie Policy Cookie policy | IMI (“Cookie Policy”).
2. How do we use personal information?
In this section, we set out the purposes for which we use and share personal information that we collect. If you are in a country in the EEA or in the United Kingdom, in compliance with our obligations under applicable data protection laws, we also identify the “legal bases” (explained further in section 3) on which we rely to process the information.
Purpose | Details | Legal Basis |
|---|---|---|
| Providing our products and services | We will need your personal information (including Basic Account Information and Sales and Transaction Information) to provide our products and administer our services effectively, including to provide you with information services and products that you have requested (e.g., a catalogue), to create and run your user sales account, to process your order and carry out our obligations arising from any contracts entered into between you and us and to provide support and after-sales services to you, including but not limited to administering return or refund policies and any changes and updates to our products and service. This includes passing your data to third parties such as agents, business partners, group companies, contractors or to our advisors (e.g. legal, financial, business or other advisors). | Contract performance (where you are in individual), legitimate interests (to enable us to perform our obligations and provide our products and services to you). |
Improving our products and services | We collect your personal information (including Basic Account Information, Sales and Transaction Information, Comments, Survey and Feedback Information, Website and Communication Usage) for improving our products and services including training of AI components, for purposes of internal training, quality control and research and development. This includes passing your personal information to third parties such as business partners, suppliers and/or service providers. Where possible we will aggregate and/or anonymise your personal information when using for such purposes. | Legitimate interests (to enable us to improve our products and services) and Consent (where required by applicable data protection law). |
Ensuring Website content is relevant | We use your personal information (including Basic Account Information, Sales and Transaction Information, Comments, Survey and Feedback Information, Website and Communication Usage) to analyse how you use our Websites, and to ensure that the content, services and advertising that we offer are tailored to your needs and interests and to provide you with suggested local distributors who stock products that you are interested in, which includes passing your personal information to third parties such as business partners, suppliers and/or service providers. We also aggregate and/or anonymise your personal information for such purposes. | Legitimate interests (to allow us to provide you with the content and services on the Websites) and Consent (where required by applicable data protection law). |
Conducting compliance checks and reporting | If you or an entity you are related to seeks to do business with Climate Control, places an order and/or opens a sales account with us then we will use your personal information (including KYC Information) for trade screening against international restricted and denied parties lists and as required by applicable law, regulation and best practice at any given time. If false or inaccurate information is provided and fraud is identified or suspected, details are passed to fraud prevention agencies and are recorded by us or by them. Information about you will also included if you make a report, or your information is included by another individual, in a report made via our whistleblowing hotline. | Legal obligations, legitimate interests (to ensure that your organisation falls within our acceptable risk profile and to assist with the prevention of crime and fraud and to protect Climate Control and its employees). Where this includes special categories of personal information, we will rely on substantial public interests (processing for the prevention and detection of fraud/crime). |
Marketing | We process your Marketing Information to contact you to provide the latest updates and offers where we are legally permitted to do so. We market to you by post, e-mail, SMS or over the telephone. Where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you can opt out by contacting us as set out in section 13 below. | Consent (where required) or legitimate interest (to keep you updated with news in relation to our products and services). |
Facilitating visits to our physical premises | Where you visit one of our physical sites, we obtain information about you (Visitor Information) to facilitate your visit and ensure health and safety of all individuals. | Legal obligations, legitimate interests (to ensure that the safety and security of premises). |
Monitoring and quality control | For quality control and training purposes, we process Communication Information and monitor or record your calls with us and any "online chat" service (when this is available). When you use any online chat function, we will collect your name, email address and chat logs. | Legal obligations, legitimate interests (to ensure the quality of our services). Where this includes special categories of personal information, we will rely on the legal basis of necessary for legal claims. |
Reorganising our business | In the event that we are (i) subject to negotiations for the sale of our business or part thereof to a third party, (ii) sold to a third party or (iii) undergo a re-organisation, we need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We also need to transfer your personal information to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this Privacy Policy. | Legitimate interests (in order to allow us to change our business). |
Protecting interests of Climate Control and ensuring legal or regulatory compliance | We process your personal information including Basic Account Information, Sales and Transaction Information and KYC Information) and other information as required by law to comply with any regulatory requirements that apply to us and to respond to queries from regulatory authorities.
| Legal obligations, legitimate interests (to protect Climate Control and its employees and to cooperate with law enforcement and regulatory authorities). |
3. How we lawfully process your personal information
For the purposes of UK and EEA data protection laws, we are allowed to process your personal information by relying on the legal bases as set out in section 2 above. We provide further explanation on the legal bases of processing below:
Legitimate Interests: We are permitted to process your personal information if it is based on our “legitimate interests” i.e. we have good, sensible, practical reasons for processing your personal information which is in our interest. These interests are effectively the purposes of our processing of your personal information set out in section 2. For example, we have legitimate interests to collect and process your personal information in order to provide our products and services to you. To rely on this legal basis, we have considered the impact on your interests and rights, and have placed appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible. You can object to the processing of your personal information that relies on legitimate interests. Please refer to the section 13 for more information.
Contract performance: We can rely on this legal basis where we process your personal information to deliver a contractual service to you where we have directly entered into the relevant contract with you (as an individual).
Consent: Sometimes we want to use your personal information in a way that is optional for you. For example, for us to process your personal information in relation to our use of specific types of cookies we will ask for your consent unless there is an alternative legal basis under the applicable data protection laws. Where you have given your consent, you can withdraw it at any time through various means including using the relevant cookie consent mechanism or by writing to us using the contact details in section 13.
Necessary for compliance with a legal obligation: We rely on this legal basis where we are required to comply with a legal obligation.
Necessary for legal claims: We can process personal information if the processing is necessary for the establishment, exercise or defence of legal claims.
Necessary for substantial public interests: We can process personal information if it is necessary for reasons of substantial public interest, specifically for the prevention and detection of fraud/crime.
4. To whom do we disclose your personal information?
We share information internally and externally as permitted under the applicable laws. Disclosures will be made to third-party service providers, contractors, agents and advisors (e.g. legal, financial, business, or other advisors) to the extent required and other members of the Group that perform essential business activities (such as technology and logistics providers) for and on behalf of Climate Control.
Where we provide personal information to service providers, we shall only disclose what is necessary to deliver the specific service, or as required by law. We take reasonable measures to ensure service providers and data processors (as defined in the applicable data protection laws in the UK/EEA) keep your information secure and oblige them by contract not to use information for their own purposes. We will carry out the required contractual, technical and organisational measures to ensure that your personal information is processed only to the extent necessary and in accordance with applicable data protection laws.
We disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings, or investigations by such parties anywhere in the world where compelled or permitted to do so. Where required by law, we will direct any request to disclose information to law enforcement agencies or other third parties to you or notify you before responding.
5. Where is personal information processed?
Together with other members of IMI’s Climate Control sector, we are subsidiaries of IMI plc which is based in the United Kingdom. We are a multinational group with offices globally. Your personal information is transferred, accessed, processed or stored in countries around the world. Regardless of location, we will, where necessary, put in place appropriate safeguards including during transfer to ensure your information is adequately protected in compliance with the applicable data protection laws. This includes encryption where possible. We store the information we collect in the United States or in other countries where we or our service providers have facilities. We transfer information to countries outside of your country of residence, including the United States, which may have data protection laws and regulations that differ from those in your country. Where local laws regulate transfer of data, such as in UK, Europe and China, we will comply with such requirements.
Any transfers of information originating from within the EEA, the United Kingdom, and Switzerland to countries outside the EEA, UK, or Switzerland will normally be made on the basis of the standard contractual clauses approved by the European Commission for transfers from EU controllers to non-EU controllers, which are available at the Commission's website at https://ec.europa.eu.
6. How long do we keep your personal information?
Our retention periods for personal information are based on business needs and applicable legal requirements. We will keep your information for as long as is necessary for the processing purpose(s) for which they were collected and any other permitted linked purpose. For example, we retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When we no longer have a purpose for retaining your personal information, we will destroy it and take commercially reasonable measures to make sure that the information is irrecoverable and irreproducible.
7. How are cookies used?
For detailed information on the cookies we use please see Cookie policy | IMI. Where required by law, you will be provided the option to reject or accept cookies that are not strictly necessary. Where other Websites use additional cookies, specific information and additional options to reject or accept cookies, that are not strictly necessary, shall be provided on these Websites.
8. What about Third-Party websites?
Our Websites contain links to third-party sites which we do not operate or endorse. These websites may use cookies and collect your personal information in accordance with their own privacy policies. This Privacy Policy does not apply to third-party websites, and we are not responsible or liable for third-party websites, their policies, or their processing of your personal information.
9. How do we protect your personal information?
We take appropriate physical, electronic and procedural measures to protect the personal information. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. When we pass your personal information to a third party, we seek to ensure that they have appropriate security measures in place to keep your personal information safe and to comply with general principles in relation to data protection. However, no data transmission over the internet or Websites can be guaranteed to be secure from intrusion and cannot guarantee absolute security.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential and complying with any other security procedures that we notify you of. Please do not share a password with anyone.
When you are on any third-party website that asks you for confidential information, you should check that the third party is a trusted source and if the information being transmitted is encrypted to increase the security of your information. Keep in mind that there is no such thing as perfect security.
10. What rights do individuals have?
Depending on the jurisdiction in which you are located, you have certain rights with respect to your personal information. If you wish to exercise your legal rights, please contact us as set out in section 13 below. We will process your request in accordance with any applicable legal requirements.
Many laws provide specific rights to individuals, including countries in EEA UK, Switzerland, Mexico, Brazil, South Korea, Japan, China, Singapore, Australia and California.
Depending on the specific laws that apply to the processing of your personal information, you have the following rights:
Right to rectification (to have incorrect or incomplete personal information updated)
Right of subject access (to determine and receive a copy of your personal information held by or on our behalf)
Right to be forgotten (to have your personal information deleted or removed it if is no longer necessary for the purposes of processing as set out in this Privacy Policy)
Right to restrict processing (to limit the way that we use your personal information)
Right to data portability (to obtain and reuse your data for your own purposes)
Right to object to processing (where we are relying on legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground)
Right to reject automated decision making (including profiling, where the decision has a legal or significant impact on you)
If you exercise any of these rights, we will check your entitlement and respond in most cases within a month or as required by law.
11. Marketing
Individuals have the right to ask us not to process personal information for direct marketing purposes. Where legally required, we will inform you if we intend to use your personal information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by not checking certain boxes on the forms we use to collect your personal information. You can also exercise the right at any time by contacting us as set out in section 13 below.
12. Updating information
We will use reasonable endeavours to ensure that your personal information is accurate. To assist us with this, please notify us of any changes to the personal information that you have provided to us by contacting us as set out in section 13 below.
13. Contact Us
Where required by local law, Climate Control has nominated country Data Protection Officers. To exercise your rights regarding your personal information, or to contact a Data Protection Officer, or if you have questions, please email us at [email protected] or Data Privacy c/o Legal Department, IMI Hydronic Engineering International SA, Route de Crassier 19, Lake Geneva Business Park, 1262 Eysins, Vaud, Switzerland.
When you contact us, please indicate in which country and/or state you reside. Please provide as much information as possible to allow us to understand and evaluate your request so that we can substantively respond to you. In some cases, we need to verify your identity.
If you are not satisfied with our use of your personal information or our response to any exercise of your rights, you have the right to contact/lodge a complaint to the data protection regulator in the country in which you are based including the following:
EU Data Protection Authorities (DPAs)
Swiss Federal Data Protection and Information Commissioner (FDPIC)
Information Commissioner’s Office (United Kingdom)
Brazil, the Autoridade Nacional de Proteção de Dados (ANPD)
14. Updates to this Privacy Policy
We regularly update this Privacy Policy and will include the last updated date and we encourage you to review this Privacy Policy from time to time. Where required by law, we will notify you of changes.
This Privacy Policy was last updated on 6 February 2026.